Procurement Policy

1. Policy Statement

Brussels College is committed to conducting all procurement activities with integrity, transparency, and accountability. This Procurement Policy establishes clear principles and procedures to ensure that all purchases of goods, services, and works deliver value for money, meet quality standards, comply with legal and ethical requirements, and support our institutional values including sustainability and social responsibility. We are committed to fair competition, equal treatment of suppliers, and ethical business practices in all procurement activities.

2. Scope and Application

This policy applies to:

• All procurement of goods, services, and works by Brussels College
• All staff authorized to make purchases on behalf of the institution
• All departments, programs, and budget holders
• Procurement from all funding sources (institutional funds, grants, donations)
• All suppliers, contractors, and service providers
• Procurement activities of any value (with procedures proportionate to value and risk)

3. Procurement Principles

3.1 Value for Money

Value for money is the optimal combination of whole-life cost and quality to meet institutional requirements. It encompasses:

• Economy: Minimizing the cost of resources while maintaining appropriate quality
• Efficiency: Maximizing outputs for given inputs or minimizing inputs for given outputs
• Effectiveness: Achieving intended outcomes and meeting institutional objectives
• Equity: Fair and accessible procurement processes

3.2 Competition and Fairness

• Promote open and fair competition among suppliers
• Treat all suppliers equally and without discrimination
• Avoid favoritism, conflicts of interest, or anti-competitive practices
• Provide clear, accessible procurement opportunities
• Award contracts based on objective, transparent criteria

3.3 Transparency and Accountability

• Document all procurement decisions and maintain audit trails
• Publish procurement opportunities and contract awards appropriately
• Clearly define roles, responsibilities, and authorization levels
• Monitor and report on procurement performance
• Enable scrutiny by internal audit, external audit, and stakeholders

3.4 Integrity and Ethics

• Comply with all applicable laws, regulations, and ethical standards
• Prevent bribery, corruption, fraud, and conflicts of interest
• Maintain confidentiality of commercial information
• Avoid any appearance of impropriety
• Promote ethical practices throughout the supply chain

3.5 Sustainability and Social Responsibility

• Consider environmental impact in procurement decisions
• Support sustainable and ethical sourcing practices
• Promote diversity and inclusion among suppliers
• Encourage fair labor practices and human rights compliance
• Support local and social enterprises where appropriate

4. Procurement Thresholds and Procedures

Value (EUR)	Procedure	Approval Required	Competition Requirements
Up to €500	Direct Purchase	Budget holder	None (but seek best value)
€501 - €5,000	Quotation	Department head	Minimum 2 verbal/email quotations
€5,001 - €25,000	Written Quotations	Vice Rector	Minimum 3 written quotations
€25,001 - €50,000	Competitive Tender	Rector + Vice Rector	Formal tender, published opportunity
Over €50,000	Formal Tender	Board of Governors	Full competitive tender, evaluation panel

5. Procurement Process

5.1 Needs Identification and Specification

1. Define Requirements: Clearly specify what is needed, including quality standards, quantities, and delivery timelines
2. Budget Verification: Confirm budget availability before commencing procurement
3. Market Research: Understand market options, pricing, and supplier capabilities
4. Specification Development: Prepare detailed specifications focusing on outputs and performance rather than prescriptive inputs
5. Sustainability Criteria: Incorporate environmental and social considerations into specifications

5.2 Sourcing and Supplier Selection

For purchases requiring quotations (€501+):

1. Issue Request for Quotation (RFQ): Provide clear specifications, evaluation criteria, and submission deadlines
2. Supplier Selection: Invite quotations from appropriate suppliers (including diverse and local suppliers where suitable)
3. Equal Treatment: Provide all suppliers with the same information and opportunities
4. Clarifications: Answer supplier questions transparently and share responses with all participants
5. Quotation Receipt: Receive quotations by deadline and maintain confidentiality

For formal tenders (€25,000+):

1. Tender Documentation: Prepare comprehensive tender documents including specifications, terms and conditions, evaluation criteria
2. Publication: Advertise tender opportunity on Brussels College website and relevant platforms
3. Tender Opening: Open tenders at prescribed time with multiple witnesses
4. Evaluation Panel: Convene evaluation panel with appropriate expertise and no conflicts of interest
5. Due Diligence: Conduct financial, technical, and reputational checks on shortlisted suppliers

5.3 Evaluation and Award

Evaluation Criteria:

Contracts are awarded based on the most economically advantageous tender (MEAT), considering:

• Price (typically 30-60%): Total cost of ownership including whole-life costs
• Quality (typically 20-40%): Technical quality, specifications compliance, performance
• Delivery/Service (typically 10-20%): Timelines, service levels, support
• Sustainability (typically 5-15%): Environmental and social impact
• Innovation (optional 5-10%): Value-added features or improvements

Evaluation Process:

1. Compliance Check: Verify quotations/tenders meet minimum requirements and specifications
2. Scoring: Score each tender against published criteria using scoring matrix
3. Clarifications: Seek clarifications from suppliers if needed (without changing tender content)
4. Moderation: Panel discusses scores and reaches consensus
5. Recommendation: Document evaluation outcome and recommend supplier for award
6. Approval: Obtain approval from authorized signatory per threshold table

5.4 Contract Award and Management

Contract Award:

• Issue written contract or purchase order to successful supplier
• Notify unsuccessful suppliers with feedback if requested
• Record award decision and rationale in procurement file
• Publish contract award information (for contracts over €25,000)

Contract Management:

• Appoint contract manager responsible for monitoring performance
• Monitor delivery, quality, and compliance with contract terms
• Conduct regular supplier performance reviews
• Manage contract variations and extensions in accordance with procedures
• Process invoices and payments within agreed terms
• Maintain contract records and documentation

6. Supplier Management

6.1 Supplier Qualification

Before awarding significant contracts, Brussels College assesses supplier capability:

• Financial Stability: Review financial statements, credit ratings, insurance coverage
• Technical Capability: Verify experience, qualifications, certifications, and references
• Legal Compliance: Confirm registration, licenses, tax compliance, and legal standing
• Ethical Standards: Assess compliance with anti-bribery, labor standards, and sustainability policies
• Past Performance: Review track record, references, and any previous issues

6.2 Supplier Diversity

Brussels College encourages diversity in our supplier base by:

• Actively seeking quotations from diverse suppliers (women-owned, minority-owned, social enterprises)
• Removing unnecessary barriers to participation by small and medium enterprises (SMEs)
• Disaggregating large contracts into smaller lots where appropriate
• Supporting capacity building for local and emerging suppliers

6.3 Supplier Code of Conduct

All suppliers must comply with Brussels College Supplier Code of Conduct, which requires:

• Legal Compliance: Adherence to all applicable laws and regulations
• Anti-Bribery: Zero tolerance for bribery, corruption, and facilitation payments
• Labor Standards: Fair wages, safe working conditions, no forced or child labor
• Environmental Responsibility: Minimize environmental impact and comply with regulations
• Data Protection: Protect personal data and respect privacy rights
• Ethical Conduct: Maintain integrity, transparency, and fair dealing

6.4 Supplier Performance Management

Contract Value	Performance Review Frequency	Performance Criteria
Under €5,000	Ad hoc (issue-based)	Delivery on time, quality, compliance
€5,000 - €25,000	Annual	Delivery, quality, value, responsiveness
Over €25,000	Quarterly	KPIs, SLAs, quality, innovation, sustainability

Poor Performance: Suppliers with persistent performance issues may face:

• Formal performance improvement plans
• Contract termination for material breach
• Exclusion from future procurement opportunities

7. Sustainable and Ethical Procurement

7.1 Environmental Sustainability

Brussels College integrates environmental considerations into procurement:

• Energy Efficiency: Prioritize energy-efficient equipment and appliances
• Waste Reduction: Minimize packaging, promote reusable/recyclable materials
• Sustainable Materials: Prefer recycled, renewable, and sustainably sourced materials
• Carbon Footprint: Consider transport emissions and supply chain carbon impact
• Product Lifecycle: Evaluate whole-life environmental impact, not just initial purchase
• Certifications: Favor products with recognized environmental certifications (EU Ecolabel, Energy Star, FSC)

7.2 Social Responsibility

• Fair Trade: Support fair trade products where available and appropriate
• Labor Rights: Ensure suppliers respect workers' rights and provide safe working conditions
• Human Rights: Exclude suppliers with human rights violations in their supply chains
• Local Sourcing: Support local economy by purchasing from Belgian/EU suppliers when value for money is comparable
• Social Enterprises: Consider social value and community benefit in procurement decisions

7.3 Conflict Minerals and Ethical Sourcing

Brussels College requires suppliers to:

• Avoid conflict minerals (tin, tungsten, tantalum, gold) from conflict zones
• Provide transparency on supply chain sources
• Certify compliance with Dodd-Frank Act and EU Conflict Minerals Regulation
• Implement responsible mineral sourcing policies

8. Conflicts of Interest

8.1 Declaration Requirements

All staff involved in procurement must:

• Declare any actual, potential, or perceived conflicts of interest before participating in procurement
• Disclose financial interests in suppliers or their competitors
• Declare personal or family relationships with suppliers or their employees
• Report gifts, hospitality, or benefits offered by suppliers

8.2 Prohibited Activities

• Accepting bribes, kickbacks, or improper benefits from suppliers
• Providing confidential information to preferred suppliers
• Steering contracts to suppliers with whom you have a relationship
• Using your position for personal gain
• Participating in procurement where a conflict exists without proper management

9. Procurement Documentation and Records

9.1 Required Documentation

Procurement files must contain:

• Business case and needs justification
• Budget approval and authorization
• Specifications and tender/quotation documents
• List of suppliers invited and responses received
• Evaluation scoresheets and panel notes
• Award decision and approval
• Contract or purchase order
• Invoice, payment, and delivery records
• Performance reviews and correspondence

9.2 Record Retention

Document Type	Retention Period	Rationale
Procurement files (under €5,000)	3 years	Audit requirements, warranty period
Procurement files (€5,000+)	7 years	Financial regulations, audit, legal
Contracts	7 years after contract end	Legal and audit requirements
Failed tenders	2 years	Potential challenges, appeals

10. Exceptions and Emergency Procurement

10.1 Single Source/Direct Award

Direct award without competition is permitted only in exceptional circumstances:

• Sole Source: Only one supplier can provide the goods/services (must be evidenced)
• Compatibility: Purchase must be compatible with existing systems and no alternatives exist
• Intellectual Property: Supplier holds exclusive rights (patents, copyrights)
• Emergency: Urgent requirement where competition is not feasible (see below)

Approval: Single source awards over €5,000 require Vice Rector approval with written justification.

10.2 Emergency Procurement

In genuine emergencies (immediate health/safety risk, critical service failure), standard procedures may be abbreviated:

• Procurement can proceed with verbal approval from Vice Rector
• Competition sought where possible, even if informal
• Full documentation and retrospective justification required within 5 working days
• Emergency provisions may not be used to circumvent normal procedures

11. Roles and Responsibilities

11.1 Vice Rector (Chief Procurement Officer)

Dr. İbrahim Çıloğlu

• Overall responsibility for procurement policy and compliance
• Approve procurements within authorization limits
• Oversee procurement processes and provide guidance
• Manage supplier relationships and contracts
• Monitor procurement performance and value for money

11.2 Budget Holders

• Ensure procurement is necessary and within budget
• Prepare specifications and define requirements
• Follow procurement procedures appropriate to value and risk
• Obtain competitive quotations/tenders as required
• Evaluate quotations objectively against published criteria
• Manage contracts and monitor supplier performance

11.3 Finance Team

• Verify budget availability before procurement proceeds
• Process purchase orders and payments
• Maintain procurement records and contracts register
• Monitor compliance with authorization limits
• Provide procurement data for reporting and analysis

12. Monitoring and Compliance

12.1 Procurement Monitoring

• Monthly review of procurements and compliance with thresholds
• Quarterly reporting to senior management on procurement activity
• Annual reporting to Board on procurement performance, savings, and risks
• Regular audits of procurement files and processes

12.2 Non-Compliance

Failure to comply with this Procurement Policy may result in:

• Invalidation of procurement and contract
• Disciplinary action against responsible individuals
• Financial loss recovery from individuals if negligence or misconduct proven
• Referral to authorities if fraud or corruption suspected

13. Policy Review

This Procurement Policy is reviewed annually and updated to reflect:

• Changes in procurement regulations and best practices
• Lessons learned from procurement activities and audits
• Institutional strategic priorities and sustainability goals
• Feedback from staff, suppliers, and stakeholders

14. Contact Information

Chief Procurement Officer:
Dr. İbrahim Çıloğlu, Vice Rector
Email: i.chiloglu@brucol.be
Phone: +32 471 09 6641

General Enquiries:
Email: office@brucol.be
Phone: +32 471 09 6641

Procurement Enquiries:
Email: procurement@brucol.be